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The Honorable Thomas Wheeler
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Dear Chairman Wheeler:
We commend your efforts to continue modernization of the Universal Service Fund
(USF), and we particularly appreciate your willingness to tackle some of the
unanswered questions that remain for many of the carriers utilizing the fund. In
conjunction with these ongoing efforts, we call on the Federal Communications
Commission (FCC) to adopt and implement a Connect America Fund (CAF)
mechanism for areas served by rural rate-of-return-regulated carriers that is both
tailored to the unique circumstances those areas face, and will provide sufficient and
predictable support for the upgrade and sustainability of broadband-capable networks in
the high-cost areas of the nation.
Today, because USF support is tied to voice service for rural providers under current
rules, high-cost areas served by rural carriers may receive reduced supp01i if consumers
do not take "plain old telephone service" (POTS) along with broadband. This
potentially deters broadband adoption and inhibits technological evolution. This is
concerning in light of the already-ongoing technology transition that the FCC is
working diligently to expedite and facilitate. While rural carriers have made
tremendous progress in deploying advanced networks, these outdated rules represent a
real obstacle to the broadband future toward which we are all aiming.
We recognize that USF reform involves many complex issues and difficult trade-offs.
We support measures to ensure USF funds are used responsibly and effectively within
cunent budgets while also upholding the statutory mandate that reasonably comparable
services must be made available at reasonably comparable prices. While we recognize
the FCC is working on a forward looking model for areas served by price cap
companies we hope the FCC will work with rate of return companies to create
separately designed updates that provide predictable support for the areas they serve as
well. Fmiher, we believe that an update to rural carrier support mechanisms can be
done at the same time as the work on larger carriers.
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For these reasons, we urge the FCC to move forward immediately with adopting and
implementing a carefully tailored update of the existing mechanisms that will provide
sufficient and predictable suppmt for broadband-capable networks in areas served by
rural caniers. We firmly believe that areas served by rural carriers should have the same
fundamental choices among reasonably comparable services at reasonably comparable
rates that consumers in urban areas enjoy.
Thank you for your prompt attention to this matter.
_]),.,.J G I~
· ~ ·
. . . . . .
K. Michael Conaway
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